Katie Lynn Shygelski
AND NOW COMES Respondent/Creditor NET Federal Credit Union, by and through their attorney, John Fisher, Esquire, with Objection to Motion to Redeem, and in support thereof avers:
- Admitted.
- Admitted in part and Denied in part. Only Debtor’s personal liability to Net Federal Credit Union is Dischargeable. The security interest in the subject 2017 Ford Focus (“the Vehicle”) is not subject to Discharge.
- Denied. Debtor has no equity in the Vehicle and therefore cannot exempt any interest in the Vehicle. The amount of any exemption would be zero ($0) dollars.
- Admitted in part and Denied in part. The trade-in valuation is not relevant. The market value of the Vehicle is the private party value of the Vehicle, which appears to be $7,100 as of October 9, 2025, which, upon information and belief, is less than the same valuation method would have produced on the date the Chapter 7 petition was filed on August 28, 2025. A true and correct copy of a Kelly Blue Book Private Party valuation utilizing the vehicle identification number is filed with this Objection as an Exhibit and incorporated herein by reference.
Denied. The estimate does not appear to be for repairs, such as a damaged fender, but rather for maintenance items. Upon information and belief, the difference between a Kelly Blue Book Private Party valuation and retail is that a private party sale is anticipated to leave the purchaser with maintenance issues to address. Nothing in the estimates indicates damage to the Vehicle from other than regular usage. - Denied. The replacement value is $7,100 or more, as, upon information and belief, the wear from regular usage and need to perform maintenance is built into a private party sale.
- Denied to the extent the averments of paragraph 7 are other than a statement or conclusion of law or misplaced request for relief that does not require a response.
WHEREFORE, Creditor NET Federal Credit Union respectfully prays this Honorable Court for an Order that Debtor’s Motion to Redeem be Denied, or, in the alternative, for an Order that the 2017 Ford Focus may be redeemed for $7,100, and for such other and further relief as the Honorable Court deems just and appropriate.
Respectfully Submitted,
/s/ John Fisher
John Fisher, Esquire
126 S. Main Street
Pittston, PA 18640
(570) 569-2154, fax (570) 569-2167
johnvfisher@yahoo.com